Code of Conduct

SMA Mineral and its subsidiaries (hereafter referred to as SMA Mineral) aim to be a competitive, fair, reliable, and responsible partner to our employees, customers, suppliers, stakeholders, authorities, and any other parties interacting with our company. To achieve this, we actively work on climate and environmental measures. We uphold good business ethics and strive for long-term, trust-based relationships. The Code of Conduct provides guidance by describing our values and the requirements we set for employees and business partners.

About the Code of Conduct

The foundation of the Code of Conduct is SMA Mineral's core values, which guide us in everything we do. Our Code of Conduct is based on the UN Global Compact and its ten principles in the areas of human rights, labor rights, environment, and anti-corruption. The principles of the UN Global Compact are based on the UN Declaration of Human Rights, the UN Sustainable Development Goals, the Rio Declaration, and the ILO's core conventions on labor rights.

• The Code applies to all companies within the SMA Group, and its contents must be followed and respected by all those working within the group, from the board and management to individual employees.
• We also require that our business partners (customers, collaborators, suppliers) respect and adhere to the Code.
• The Code of Conduct forms an overarching framework that must always be applied and can be complemented by detailed guidelines and procedures for specific areas.

SMA Mineral's Code of Conduct, together with our core values, is our most important document. It helps us make the right decisions in our daily work—decisions that affect us all and make both our workplace and the world a little better. This is how we take responsibility.

Our Core Values Guide Us

SMA Mineral operates based on a value system summarized by the words Competence, Reliability, Flexibility, and Innovation. This value system is a key part of the company's success and describes our shared corporate culture.

• Competence
  Competence is essential for understanding customer needs and providing the right service. The right competence is also required to ensure work is performed with the highest possible safety standards.
• Reliability
  Satisfied customers return and act as ambassadors who bring in new customers. In theory, it's that simple. In practice, it means we must always be alert and deliver on our promises, both big and small. Our reputation for reliability is built over the long term by everyone.
• Flexibility
  Sometimes challenging situations arise. This is when we show why SMA Mineral is a market leader. Through personal commitment and flexibility, we overcome many challenges.
• Innovation
  Just because something works doesn’t mean it can’t be improved. The desire to continuously improve efficiency, safety, and quality—and ultimately our competitiveness—is ingrained in our daily work and our mindset.

Human Rights and Labor Rights

We Protect Human Rights
Internationally recognized human rights must be protected and respected.

Privacy; SMA Mineral respects personal data and handles it carefully according to laws and regulations such as GDPR. We continuously work on data protection, revising, purging, and updating our records.

We Uphold the Right to Freedom of Association
SMA Mineral does not accept any restrictions on workers' rights to freedom of association or collective bargaining. Employees should be able to exercise these rights without interference or fear of retaliation, even in countries where the right to organize is limited or prohibited.

We Reject Forced and Indebted Labor
Work must be voluntary. Personal documents and belongings must not be confiscated. Employees must be free to leave the workplace after their shift. Illegal labor must not be used.

We Reject Child Labor
Any form of violence, coercion, or exploitation of children is unacceptable. A child is defined here as a person under 18 years of age, according to the first article of the UN Convention on the Rights of the Child. Workers under 18 must be specially protected from hazardous tasks that pose health and safety risks, such as night shifts.

We Reject Harassment or Discrimination
SMA Mineral has a zero-tolerance policy for all forms of harassment, bullying, and discrimination. We are responsible for preventing, stopping, and acting against it. All employees and business partners who observe or suspect violations must report them.

We Promote Equal Treatment and Diversity
The equality of all individuals is a given. SMA Mineral works to increase diversity and equal treatment in all areas of the business, and equal treatment is a fundamental requirement at all our workplaces. Everyone should have the same rights and opportunities, regardless of gender, gender identity or expression, ethnicity, religion or belief, disability, sexual orientation, or age.

Indigenous Peoples
SMA Mineral respects the rights of indigenous and tribal peoples and their social, cultural, environmental, and economic interests, including their connection to land and natural resources. This includes principles of free, prior, and informed consent, and participation.

Conflict Minerals and High-Risk Areas
SMA Mineral condemns all activities related to the illegal exploitation and trade of minerals. SMA Mineral will not, and suppliers should not, use minerals that directly or indirectly finance or benefit armed groups in conflict-affected or high-risk areas (CAHRAs).

We Prioritize a Safe Work Environment and Health
SMA Mineral's workplaces should be safe, inclusive, and secure, with no accidents. We place employee health and safety at the center.

• We work long-term and systematically to develop the work environment and promote employees' health, in order to prevent injuries and illness.
• At our workplaces, everyone must be involved in the work environment efforts and follow our guidelines and workplace rules. Employees are responsible for their own and others' work environment. We are mindful in our daily routines and take care of each other and ourselves.
• At our workplaces, applicable equipment and competence for the protection of people and property must be in place.
• We work to ensure that the entire value chain, in accordance with the respective country's work environment legislation, contributes to a healthy and safe work environment.

We Ensure Fair Employment Terms
SMA Mineral does not accept employment terms that fall below national or local laws or ILO's core conventions.

• Signed collective agreements must be respected and followed.
• Working hours and minimum wages must comply with national laws in the country where the product is manufactured or the service is performed.

Community Engagement
SMA Mineral is an integral part of the local community and supports various initiatives and projects to contribute to a better society. We maintain a transparent, honest, and open dialogue with stakeholders and authorities in and around the areas where we operate, and we require our suppliers to do the same. Community engagement should be done in an inclusive, fair, culturally adapted, and gender-conscious manner.

Environment and Labor Rights

We Care about Climate and the Environment
SMA Mineral contributes to sustainable societal development and works continuously to prevent environmental risks and minimize our impact on the environment and climate.

SMA Mineral conducts its operations in a responsible manner with respect to the environment, including climate change, and actively works to reduce the environmental risks and impacts associated with its supply chains.

• Our environmental work is integrated into the business and is carried out systematically and proactively. We aim to promote the development and use of environmentally friendly technologies and conduct business with the least possible impact on the environment and public health.
• We comply with and respect laws and other relevant environmental-related societal requirements.
• We take into account that access to preserved resources, including clean drinking water, good soil quality for agriculture, and healthy air quality, is provided to the local community.
• We strive to preserve or increase biodiversity in the areas where we operate.

We Work to Reduce the Environmental Impact of our Operations
SMA Mineral actively focuses on the areas where the business has the greatest environmental impact from a life-cycle perspective and works to:

• Phase out environmentally and health-hazardous products.
• Increase resource efficiency.
• Minimize our carbon emissions.
• Minimize waste and emissions.
• Use resources such as energy, water, land, and raw materials in an efficient and sustainable way.

If the impact cannot be completely avoided or mitigated, the possibility of compensation and restoration measures is considered.

SMA Mineral works progressively with continuous improvements to achieve better environmental performance. Employees and business partners at SMA Mineral's workplaces are responsible for reporting deviations and environmental incidents. We encourage knowledge of, as well as the development and dissemination of, environmentally friendly technology.

We Set Requirements for Business Partners
SMA Mineral's business partners and their environmental performance play an important role in our environmental work. This is captured in the procurement processes through requirements and guidelines. We will, in collaboration with our business partners, drive the development of environmentally adapted products and solutions. Our suppliers should conduct environmental work systematically to minimize environmental impact and should comply with and respect laws and other relevant environmental-related societal requirements.

Corruption, Business Ethics, and Business Principles

We Follow Laws and Regulations
SMA Mineral follows the laws, rules, and regulations that apply in the markets where we operate. We require our business partners to do the same.

We Reject Corruption
SMA Mineral always acts responsibly and ethically in business relationships. We tolerate no form of corruption, bribery, or extortion. This means:

• We act and make decisions without regard to personal gain for ourselves or our relatives. We also do not exploit relationships with business partners for personal benefit.
• We avoid situations that could create or give the impression of creating conflicts of interest. If a conflict of interest cannot be avoided, it should be reported openly to the nearest supervisor. If an employee conducts business activities outside of SMA Mineral (referred to as a secondary occupation), this must be approved by SMA Mineral.
• We never violate applicable laws regarding the giving or receiving of bribes. We neither give nor accept gifts or services of value exceeding the levels established by SMA Mineral, and do not participate in representation beyond normal business activities. We comply with the rules of business partners regarding gifts, representation, etc., if these are stricter than SMA Mineral's.

We Follow Competition Laws
SMA Mineral operates according to applicable competition laws in the markets where we work. We strive for healthy competition in tenders, offers, procurement, and purchases.

• We are committed to conducting business with high integrity and have zero tolerance for bribery and corruption.
• Our position is that competition is developmental and drives our company forward. We will comply with applicable competition laws in all areas of our business and in all markets where we operate.
• We do not accept any form of illegal anti-competitive practices, such as price-fixing, cartel formation, or abuse of market dominance.
• We act correctly and do not engage in improper influence or manipulation that distorts competition.

We Commit to Combatting Economic Crime
SMA Mineral takes responsibility for counteracting economic crime in the industry, which distorts competition and leads to instability and reduced resources for the legal part of society.

• We ensure correct accounting of financial transactions.
• We distance ourselves from and actively work against undeclared work.

Compliance

We Require Compliance with the Code of Conduct
The principles of the Code of Conduct are continuously monitored as a natural part of the business operations. Here, management and supervisors at all levels have a particularly important responsibility to lead by example. An employee who feels uncertain about the application of the code in their daily work can seek guidance from their supervisor.

Employees at SMA Mineral should raise alarms if they suspect anything that goes against the Code of Conduct or legislation. SMA Mineral provides several opportunities to report suspicions of violations. In the first instance, SMA Mineral and business partners' employees should report to their nearest supervisor. If this is not suitable for various reasons, there is the option to report anonymously via SMA Mineral's whistleblowing system, which is provided by a third party.

SMA Mineral does not tolerate any form of retaliation against employees or others on our premises who, in good faith, raise concerns about suspected or actual actions that violate this Code of Conduct.

If an employee at SMA Mineral acts contrary to the Code of Conduct, corrective actions will be taken. If a business partner repeatedly or seriously violates the Code of Conduct, the business relationship will be terminated.

SMA Mineral conducts risk-based due diligence by regularly and systematically identifying and assessing risks and consequences related to human rights, labor law issues, the environment, and business ethics within its value chain. This also includes ensuring that neither we nor our partners are involved in activities that aim to undermine civil society and citizens' freedoms. Suppliers and partners should assess whether their own operations or supply chains are in or purchase from conflict-affected areas or other high-risk areas, and in such cases, adapt and improve their due diligence measures to fit the specific context.

Persberg 2024-04-24

Svante Fielding
CEO and Group Executive

SMA Mineral AB
Box 329
682 27 Filipstad
SWEDEN

+46 590 - 164 00
sma@smamineral.se